IBM Response to the California Transparency in Supply Chains Act

January 3, 2012

The California Transparency in Supply Chains Act of 2010 (SB 657) went into effect January 1, 2012. This law requires large retailers and manufacturers that do business in the state of California, and that have gross worldwide sales of over $100 Million Dollars, to be transparent about the efforts they have undertaken to eradicate Slavery and Human Trafficking in their supply chain.

As members of the Electronic Industry Citizenship Coalition (EICC), IBM and other member firms have demonstrated our commitment to environmental and social responsibility. Since 2004, IBM (and the EICC) has built upon the Code of Conduct which prohibits the use of forced, bonded, indentured labor or involuntary prison labor. As a member of EICC, IBM audits suppliers in developing markets to the IBM/EICC code and takes seriously any non-conformance in its extended supply chain. These audits are performed by third party professionals in a scheduled manner in order to assure a thorough assessment against the code provisions.

This focus on slavery and human trafficking is part of a larger effort of supply chain transparency and accountability. IBM has taken multiple actions to verify the absence of forced labor, slavery and human trafficking in our supply chain, including the following:

Procurement professionals training: IBM Global Supply has an internal on-line course available to members of its worldwide team involved with sourcing and supplier management. The course is titled Supply Chain Social Responsibility and deals with all aspects of the Code and deployment to suppliers providing goods and services to IBM.